Privacy Policy & Cookie Policy

1. Data Controller

This website wheelgiveaway.com (hereinafter "the Site") is operated by a private individual, without a VAT number, residing in Italy. The Site is not a commercial activity and is not subject to the tax obligations applicable to businesses.

For any privacy-related inquiries, you may write to: privacy@wheelgiveaway.com

2. Data Collected by the Site

2.1 No direct collection of personal data

The Site does not collect, store, or transmit any personal data from its users. There are no:

• Registration or login forms
• User accounts
• Newsletters or contact forms
• Proprietary tracking systems
• Proprietary analytics

2.2 Data processed locally (localStorage)

The tool on the Site (the random picker wheel) uses the browser's localStorage technology to save user-entered data (participant names, draw history, preferences). This data:

• Remains exclusively on the user's device
• Is never transmitted to external servers
• Is not accessible to the Site operator or any third parties
• Can be deleted at any time by the user by clearing their browser data

2.3 Service Worker (PWA)

The Site uses a Service Worker to function as a Progressive Web App (PWA). The Service Worker caches site resources to enable offline functionality. It does not collect or transmit personal data.

3. Cookies

3.1 Cloudflare technical cookies

The Site is hosted on Cloudflare Pages. Cloudflare may set strictly necessary technical cookies for the operation and security of the site:

These cookies are strictly necessary and do not require user consent under the GDPR and the ePrivacy Directive. For more information: Cloudflare Privacy Policy .

3.2 Google AdSense cookies (third-party profiling cookies)

The Site uses Google AdSense to display advertisements. Google AdSense uses cookies and similar technologies to:

• Show personalized ads based on the user's interests
• Limit the number of times an ad is displayed
• Measure the effectiveness of advertising campaigns
• Understand user interactions with ads

The main cookies used by Google AdSense include:

These cookies require explicit user consent before being set, in compliance with the GDPR (EU Regulation 2016/679) and the ePrivacy Directive.

Users can manage their Google advertising preferences at: Google Ads Settings . For more information: Google Privacy Policy , How Google uses data from partner sites .

4. Cloudflare Web Analytics

The Site may use the basic analytics features provided by Cloudflare as part of the hosting service. Cloudflare Web Analytics:

• Does not use additional cookies
• Does not track individual users
• Only collects aggregate data (visit count, pages visited, country of origin)
• Is GDPR-compliant without requiring consent

For more information: Cloudflare Web Analytics .

5. Legal Basis for Processing

The legal bases for data processing are:

• Legitimate interest (Art. 6(1)(f) GDPR): for strictly necessary technical cookies for site operation and abuse protection.
• Consent (Art. 6(1)(a) GDPR): for Google AdSense profiling cookies, requested via the cookie banner on first visit.

6. Data Transfers Outside the EU

Google LLC, as the AdSense provider, may transfer data to the United States. Google participates in the EU-U.S. Data Privacy Framework to ensure an adequate level of protection under Art. 45 of the GDPR. For details: Google Compliance .

Cloudflare Inc. may process data on servers located outside the EU. Cloudflare also participates in the EU-U.S. Data Privacy Framework.

7. User Rights

Under Articles 15-22 of the GDPR, users have the right to:

• Access: obtain confirmation of whether their data is being processed
• Rectification: correct inaccurate data
• Erasure: request the deletion of their data
• Restriction: restrict the processing of their data
• Portability: receive their data in a structured format
• Objection: object to the processing
• Withdraw consent: withdraw consent given for profiling cookies at any time

To exercise these rights, write to: privacy@wheelgiveaway.com

Users also have the right to lodge a complaint with the Italian Data Protection Authority ( Garante per la Protezione dei Dati Personali , Piazza Venezia 11, 00187 Rome, Italy, email: protocollo@gpdp.it) or with the supervisory authority of their country of residence.

8. How to Manage or Disable Cookies

In addition to the cookie banner on the Site, users can manage cookies directly from their browser:

• Google Chrome
• Mozilla Firefox
• Safari
• Microsoft Edge

To opt out of personalized Google advertising across all sites: Your Online Choices (EDAA) .

9. Children

The Site is not intended for children under 16 years of age. The Site operator does not knowingly collect personal data from children.

10. Changes to This Privacy Policy

The operator reserves the right to update this policy at any time. Changes will be published on this page with the updated date. Users are encouraged to review this page periodically.

11. Applicable Legislation

• Regulation (EU) 2016/679 (GDPR)
• Italian Legislative Decree 196/2003 (Privacy Code) as amended by Legislative Decree 101/2018
• Italian Data Protection Authority cookie guidelines of June 10, 2021
• ePrivacy Directive 2002/58/EC